Programs in Marion County, Indiana Rachel Walker, Mundell & - - PowerPoint PPT Presentation

Groundwater Protection Programs in Marion County, Indiana

Rachel Walker, Mundell & Associates, Inc. John A. Mundell, Mundell & Associates, Inc.

Marion County/City of Indianapolis

County Population: ~904,000 over 403 sq. miles

Have you seen these?

Marion County Wellfields

Ford Wellfield – Agricultural and residential Geist – Residential and light retail Lawrence – Residential and retail Fall Creek – Retail, auto service, light industry Riverside – Retail, auto service, major industry Speedway – Retail, auto service, residential South – Retail, auto service, major industry

Wellfield Protection Regulations

• The Safe Drinking Water Act Amendments of 1986 (SDWA) established a

national priority of protecting groundwater drinking water sources from chemical contamination.

• Title 327, Article 8, Rule 4.1 of the Indiana Administrative Code

(327 IAC 8-4.1), establishes the regulatory framework for local wellhead protection programs and defines local program performance expectations:

"Time of travel (TOT) threshold" means a threshold determined by the community or CPWSS to suit the hydrogeologic conditions and needs of the community; however, a minimum five (5) year TOT for modeled wellhead protection areas and three thousand (3,000) feet for fixed radius wellhead protection area is allowed.

Wellhead Protection Area

Geology and Hydrogeology of Marion County

Current Wellfield Protection Zones vs Geology

Marion County Public Water Supply

• Three water distributors
• Citizens Water (~95%)
• Speedway Water Works (~1%)
• Lawrence Utilities (~4%)
• Almost 11 billion gallons of water are pumped

from the 85 wells across seven wellfields each year, comprising about 25% of water supply

• Demand for water is growing with the population

and growth of industry

What’s in the Wellfields?

• Approximately 2,300 active business sites
• Around 950 (41%) have been identified as potential contaminant sources

(PCS) Business Types in all Wellfields

What’s in the Wellfields?

• Of the 950 Potential Contaminant Sources, about 700 (73%) appear in a

regulatory database. Regulated Business Types in all Wellfields

Groundwater Protection Through Time in Marion County

• City Wellfield Protection Zoning Ordinance established
• City Wellfield Protection Hearing Officer

1995

• Marion County Wellfield Education Corporation (MCWEC)

Established

1996

• Technically Qualified Person (TQP) program replaces Wellfield

Hearing Officer

1998

• Wellfield Business Inventories started (MCWEC)

2007

• Marion County Public Health Department enacts a Wellfield

Protection Health Code

2017

Current Wellfield Protection Approaches in Marion County

City Wellfield Zoning Ordinance (TQP) MCWEC Outreach Program Health Department Wellfield Code

Regulation of New Development Technically Qualified Person (TQP)

• When companies want to build a new facility or improve an existing facility, they

must file for a permit with the City – Improvement Location Permit (ILP)

• If these are located within a wellfield they are flagged for review by the TQP

Regulation of New Development Technically Qualified Person (TQP)

Plans are reviewed with respect to chemical storage

Regulation of New Development Technically Qualified Person (TQP)

Construction and operational conditions are imposed on the business to ensure groundwater safety

Regulation of New Development Technically Qualified Person (TQP)

• Approximately 250 sites have been reviewed through this process
• Last update to ordinance was 2016 – introduced a ban on new underground

storage tanks in both W-1 and W-5 wellfield zones

Regulation of New Development Technically Qualified Person

Pros

– Thorough review process – Allows decisions to be made based on risks – Have new or expanding businesses build protections in from the start – Work with City zoning department for compliance enforcement

Cons

– Focused on development stage: no impact on existing businesses – Not really focused on regulating

• perations

– Re-inspections have found non- compliance issues with some businesses

Regulation of New Development Technically Qualified Person

Compliance Example

Pit filling operation in South Wellfield

– Was mandated by TQP letter that no material with adverse lab results be placed in cavity. – Inspection discovered that fill material with bad lab results was placed in cavity. – TQP required Phase II assessment of fill already in place to determine whether a threat to groundwater was present. – Re-drafted TQP letter with new guidelines to ensure material is staged and held until lab results are received.

Voluntary Assistance to Existing Businesses

Marion County Wellfield Education Corporation

(MCWEC)

• Not-for-profit corporation established in 1996

by the Marion County Wellfield Protection Zoning Ordinance

• Voluntary & confidential business outreach

and education

• Maintain database of potential contaminant

sources

• Visit potential contaminant sources in the

wellfield and offer free consulting on how to improve waste/chemical storage and handling.

• Website: http://indyH2O.org or

http://mcwec.org Mission: To prevent contamination to the valuable groundwater resources of Marion County through public awareness and education.

How bad can it possibly be?

How bad can it possibly be?

MCWEC business outreach includes donating spill equipment to businesses

MCWEC Business Outreach

Pros

– Voluntary, business friendly & aims to create positive relationships with businesses – Can see what’s really in the wellfield and what chemical storage practices people are using – Donated spill equipment encourages new practices

Cons

– Businesses most in need of help were the least likely to opt-in to receiving it – Because the program is anonymous and voluntary, no way to report significant dangers to the wellfield when observed in the field

Marion County Public Health Department Wellfield Health Code

• Drinking water protection is public health

protection

• All businesses have the same expectations

and applies to ALL businesses in the wellfields

• Passed effective 2017, enforcement began

2018

• MCPHD inspectors will visit each business,

at an interval appropriate to the business, and enforce the health code

• Violators may receive notices of violation,

fines, and/or legal action when appropriate

MCPHD Wellfield Health Code Requirements

Focus on business practices

Common Sense Practices Can Protect Drinking Water Proper Spill Kits Overfill alarms

• n tanks

Proper waste disposal Inform chemical and waste transporters Employee Training on Spill Response and Prevention Floors in good condition Chemicals properly labeled & stored

MCPHD Wellfield Health Code and MCWEC

Better results through collaboration

• Prior to the existence of the MCPHD Wellfield Code, MCWEC

encountered a relatively small number of businesses.

• Once Wellfield Code enforcement began in 2018, that number

increased substantially. Businesses are invited to contact MCWEC for compliance assistance by MCPHD inspectors.

• MCWEC responded to this increase by making more funds available for

purchasing spill and containment equipment.

• MCWEC also provides assistance on technical issues to the MCPHD

when requested.

Three-Pronged Approach to Wellfield Protection for Marion County

• City Wellfield Zoning Ordinance builds protection into new
• construction. Follow-up inspections of sites can lead to

enforcement actions to ensure compliance.

• MCWEC voluntary program has proven most effective when

providing free spill equipment to businesses. However, this program

• riginally interacted with only a small number of businesses. After

the MCPHD Wellfield Code came into effect, that number has increased substantially. MCWEC also provides technical support to the MCPHD.

• MCPHD Wellfield Health Code is in its first year of enforcement.

MCPHD inspections have prompted many more businesses to make use of MCWEC services.